Medical Journal Houston | Page 3

May 2016
Medical Journal - Houston Page 3
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FINANCIAL PERSPECTIVES
BY REED TINSLEY , CPA , CVA , CFP , CHBC
It is important for all employers , including those in the healthcare industry , to conduct exit interviews with departing employees . The consistent use of exit interviews serves numerous purposes , including protection of sensitive business information , achievement of overall improvement in workplace environment , and curtailment of employee turnover .

The exit interview : a tool for litigation avoidance and corporate healthcare compliance

misleading documents were submitted to a government agency ; 3 ) expense reports were padded or falsified ; 4 ) items of value were offered or accepted for referrals , or 5 ) legal or regulatory violations were covered up . To that end , the following topics should be explored :
• Did the employee witness any conduct that he or she would characterize as either unethical or illegal ?
• Was the employee ever asked to engage in conduct that he or she believed to be either unethical or illegal ?
• Has the employee heard rumors or reports of unethical or illegal conduct which he or she considered credible ?
• Were any company documents , including documents created by the employee , removed from the institution and not returned ? Does the employee have any copies of documents anywhere off premises ?
• Has the employee ever given company documents to persons not employed by the facility ? Has anyone else at the facility done so ?
• Has any government investigator , agent , or attorney interviewed the
Please see FINANCIAL PERSPECTIVES page 15
Using the Exit Interview
Exit interviews provide additional benefits to entities that deal with and are regulated by the federal government , such as those in the healthcare industry . With the numerous regulations and certification requirements applicable to healthcare facilities , exit interviews should be part of an institution ’ s overall compliance program . An effective healthcare compliance program will permit an entity to identify and address possible regulatory or statutory violations , as well as provide information necessary to assess the potential for litigation .
Healthcare facilities that participate in government reimbursement programs must be sensitive to fraud and abuse litigation under various statutes , including the anti-kickback statute , the Stark law ( antiself-referral ), and a number of civil and criminal statutes addressing false claims and fraudulent billing . Attention to these compliance issues will , in turn , lessen the possibility that an entity will become the target of an investigation by the OIG , HCFA , HHS , the DOJ , or some other federal or state agency .
Healthcare employers should also use the exit interview to gauge the possibility of “ general ” employment litigation , such as a claim by a departing employee for wage payment , harassment , or discrimination .
In order to address issues of compliance , and to prevent or prepare for litigation , exit interviews should be used to elicit information concerning illegal or unethical behavior , workplace quality , personnel issues such as quality of training / supervision , and other issues stemming from the employment relationship generally .
Uncovering Damaging or Illegal Behavior
When probing the possibility of illegal or unethical behavior or practices in the workplace , a healthcare employer should explore whether an employee knows of circumstances suggesting that 1 ) billing or medical records were altered ; 2 ) false or